Text For Citation: 01 Item/Group: 012 Hazard: REFINERY

29 CFR 1910.119(j)(4)(ii) Inspection and testing procedures did not follow recognized and generally accepted good engineering practices. The employer does not follow RAGAGEP (API 570) for piping inspection when it failed to include the appropriate thickness measurements (previous thickness) for Piping Circuit P020L500-X in its calculation of corrosion rates in 2009. The employer violated this standard on or about March 14, 2011 when the employer did not complete the corrosion analysis required for inspections on P020L500-X piping circuit. Not being able to ascertain what the corrosion rate is might result in not knowing if the corrosion rate has exceeded the expected rate; this factor is even more crucial for thickness monitoring as the piping circuit approaches its retirement date. API 580, Section 5.5.1, states that the rate of deterioration is one of the four factors affecting the probability of equipment failure, and it has not been monitored closely in this case. Without a thorough inspection plan and assessment based on historical data, the piping systems can't be operated reliably and efficiently. Pursuant to 29 CFR 1903.19(d), within 10 days, the employer must submit an abatement plan describing the actions it is taking to ensure that corrosion analysis is completed in a timely manner after inspections. The violation must be abated no later than 10 days from the receipt of this citation.